Privacy Policy

This Privacy Policy ("Policy") is issued by sukacuci ("we", "us", "our"), the operator of the online gaming platform accessible at sukacuci.cam. This Policy governs the collection, use, storage, transfer, and protection of personal data belonging to individuals who access, register on, or otherwise interact with the sukacuci platform.

By registering an account or using any part of the sukacuci platform, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection and processing of your personal data in the manner described herein. If you do not agree with any part of this Policy, you should cease using the platform immediately.

This Policy is to be read in conjunction with sukacuci's Terms & Conditions and Responsible Gambling Policy, both of which are incorporated by reference.

For the purposes of this Privacy Policy, the following terms carry the meanings set out below:

sukacuci collects the following categories of personal data, depending on how you interact with the platform:

Identity & Contact Data

• Full legal name as it appears on your government-issued identity document.
• Date of birth (for mandatory age verification — 21+ policy strictly enforced).
• Residential address, including city (e.g., Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam) and postcode.
• Email address and mobile phone number.
• National identity card number or passport number (for KYC verification).

Financial & Payment Data

• Payment method details sufficient to process deposits and withdrawals (e.g., bank account reference for FPX and DuitNow transactions, e-wallet account identifier for Touch 'n Go eWallet, Boost, or GrabPay).
• Transaction history including deposit amounts, withdrawal requests, game wagering records, and bonus redemption activity, all denominated in MYR.
• Documentation evidencing source of funds, where requested during enhanced due diligence.

Technical & Behavioural Data

• IP address, device type, operating system, and browser type collected automatically upon platform access.
• Session duration, pages visited, game titles played, and betting patterns, used for platform optimisation and responsible gambling monitoring.
• Geolocation data at the city level, used for jurisdiction verification and fraud prevention.

sukacuci collects personal data through the following channels:

• Direct Provision: Information you provide when registering an account, completing KYC verification, contacting customer support, or filling in any form on the platform.
• Automated Technologies: Data collected automatically through cookies, web beacons, server logs, and similar tracking technologies when you access the platform via any device.
• Third-Party Verification Services: Identity and age verification data obtained from licensed third-party KYC service providers in connection with your account registration and withdrawal requests.
• Payment Processors: Transactional data shared by certified payment gateway providers including FPX, DuitNow, and e-wallet operators (Touch 'n Go, Boost, GrabPay) in connection with deposit and withdrawal processing.
• Fraud Prevention & Security Services: Risk-related information received from fraud detection service providers engaged to protect the platform and its players from fraudulent activity.

sukacuci processes your personal data for the following specific purposes:

sukacuci processes personal data on the following legal grounds, as applicable to each processing activity:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions, including account management, payment processing, and delivery of gaming services.
• Legal Obligation: Processing required to comply with anti-money laundering regulations, KYC requirements, and any other applicable legal or regulatory obligations imposed by our operating licence jurisdiction.
• Legitimate Interests: Processing conducted for fraud prevention, platform security, responsible gambling monitoring, and internal analytics, where such processing does not override the fundamental rights of the data subject.
• Consent: Processing of data for optional marketing communications, which is conducted only where the player has given a freely given, specific, informed, and unambiguous consent. Consent may be withdrawn at any time.

sukacuci does not sell, rent, or trade your personal data. We may disclose personal data to the following categories of third parties, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment Service Providers: FPX gateway operators, DuitNow facilitators, and e-wallet providers (Touch 'n Go eWallet, Boost, GrabPay) receive transactional data necessary to process your deposits and withdrawals.
• KYC & Identity Verification Services: Licensed third-party identity verification platforms receive the personal and documentary information necessary to complete your KYC process.
• Fraud Prevention & Risk Management Services: Security service providers receive limited data to assess and mitigate fraud risk, in accordance with data processing agreements.
• IT Infrastructure Providers: Cloud hosting and server infrastructure providers who store platform data subject to strict confidentiality and security obligations.
• Regulatory & Law Enforcement Authorities: Where required by applicable law, court order, or regulatory obligation, sukacuci may disclose personal data to relevant authorities. We will notify affected players of any such disclosure where permitted by law.

sukacuci retains personal data only for as long as is necessary to fulfil the purposes set out in this Policy, or as required by law. The following indicative retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our internal data lifecycle management procedures.

sukacuci uses cookies and similar tracking technologies to improve platform functionality, maintain your session state, and gather aggregated analytics data. The following categories of cookies may be set when you access sukacuci.cam:

• Strictly Necessary Cookies: Essential for the operation of the platform, including maintaining your logged-in session and remembering your security preferences. These cannot be disabled without impairing core platform functionality.
• Functional Cookies: Used to remember your preferences such as language settings, preferred payment method display, and responsible gambling tool settings.
• Analytics Cookies: Aggregated, anonymised data collected to understand how players navigate the platform, which pages receive the most visits, and where usability improvements can be made. Individual player behaviour is not sold to advertising networks.

Subject to applicable law and the limitations outlined below, you may exercise the following rights in respect of your personal data held by sukacuci:

• Right of Access: Request a copy of all personal data sukacuci holds about you, along with information on how it is processed.
• Right to Rectification: Request correction of any inaccurate or incomplete personal data held on your account.
• Right to Erasure ("Right to be Forgotten"): Request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal retention obligations.
• Right to Restrict Processing: Request that sukacuci limit the processing of your data in certain circumstances, such as while a data accuracy dispute is being resolved.
• Right to Data Portability: Where processing is based on your consent or contractual necessity, request a machine-readable copy of the personal data you provided to sukacuci.
• Right to Object: Object to processing based on legitimate interests, including direct marketing. Where you object to marketing, sukacuci will cease all such communications immediately.
• Right to Withdraw Consent: Withdraw consent for any processing activity conducted on a consent basis at any time without affecting the lawfulness of processing conducted prior to withdrawal.

To exercise any of these rights, submit a written request to [email protected]. sukacuci will acknowledge your request within 5 business days and endeavour to respond substantively within 30 days. We may request identity verification before processing a data rights request to prevent unauthorised access to another person's data.

sukacuci implements and maintains the following technical and organisational security measures to protect personal data against unauthorised access, loss, destruction, or disclosure:

• 256-bit SSL/TLS encryption on all data in transit between user devices and platform servers.
• Encryption at rest for all sensitive personal data held in sukacuci's databases.
• Strict role-based access controls ensuring that only authorised personnel with a documented operational need may access personal data.
• Regular independent third-party penetration testing and vulnerability assessments of the platform infrastructure.
• Multi-factor authentication (MFA) options available to all player accounts, and mandatory for administrative access to platform systems.
• Incident response procedures enabling sukacuci to detect, investigate, and remediate data security incidents promptly.

sukacuci enforces a strict minimum age requirement of 21 years for all registered players. The platform is not directed at, and does not knowingly collect personal data from, individuals under the age of 21.

Where sukacuci becomes aware that personal data has been collected from an individual under the age of 21, the relevant account will be immediately closed, all personal data associated with that account will be deleted or securely anonymised, and any deposits will be returned. No winnings will be paid out in respect of an underage account.

The sukacuci platform may contain references or links to third-party services, including payment providers and game studio partners. sukacuci is not responsible for the privacy practices of any third-party website or service. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of sukacuci.

The fact that a third-party service is mentioned or integrated within sukacuci does not constitute an endorsement of that party's data handling practices.

sukacuci reserves the right to amend this Privacy Policy at any time. Material changes — particularly those that affect how we use your personal data or the rights available to you — will be communicated to registered players via the email address on file with a minimum of 14 days' notice prior to the updated Policy taking effect.

The most current version of this Policy will always be accessible at sukacuci.cam/privacy-policy. The "Effective date" at the top of this page indicates when the current version was last reviewed and published. Continued use of the platform following the effective date of any amendment constitutes acceptance of the revised Policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact our Data Support team using the following details:

sukacuci is committed to resolving all privacy-related concerns promptly and fairly. If you are not satisfied with our response to your complaint, you may escalate the matter to the applicable data protection supervisory authority in the jurisdiction under which our operating licence is issued.